Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT held the reassessment invalid and set aside the reopening. The Tribunal found the AO had examined and allowed the assessee's deduction under s.80IA during original assessment on receipt of Form 10CCB and project accounts, and the reassessment was prompted solely by a change of opinion without fresh tangible material. The Revenue's alternative grounds - reduction of s.80IA profits in computing other Chapter VIA deductions, concurrent claims under s.80HHC and s.80HHE, and disallowance of prior period expenses - were rejected as contrary to binding principles and on facts. The reassessment order was quashed and the assessee's assessments restored.
ITAT held the reassessment invalid and set aside the reopening. The Tribunal found the AO had examined and allowed the assessee's deduction under s.80IA during original assessment on receipt of Form 10CCB and project accounts, and the reassessment was prompted solely by a change of opinion without fresh tangible material. The Revenue's alternative grounds - reduction of s.80IA profits in computing other Chapter VIA deductions, concurrent claims under s.80HHC and s.80HHE, and disallowance of prior period expenses - were rejected as contrary to binding principles and on facts. The reassessment order was quashed and the assessee's assessments restored.
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